Privacy Notice

Last updated: April 2026

1. Introduction

This Privacy Notice describes how Lumen Capital ("Lumen Capital," "we," "us," or "our") collects, processes, and protects personal information in connection with our website and the engagements we conduct with qualified counterparties.

Lumen Capital operates as a private investment and advisory platform. Our work is bilateral, confidential, and conducted under professional standards. This notice applies to information collected through this website and through direct engagements with the firm.

2. Information We Collect

Information you provide

When you submit an inquiry through our contact form or correspond with the firm, we may collect:

• Identifying information (name, entity, jurisdiction)
• Contact information (email, professional address)
• Counterparty type and professional capacity
• Content of your inquiry and subsequent correspondence
• Information required for institutional onboarding (KYC, AML, qualified investor verification)

Information collected automatically

When you visit our website, we may collect:

• Technical information (IP address, browser type, device characteristics)
• Usage information (pages visited, time spent, referring source)
• Cookies and similar technologies, subject to your consent

3. How We Use Information

Personal information is used to:

• Respond to inquiries and conduct counterparty verification
• Evaluate suitability and mandate alignment
• Comply with applicable regulatory and legal obligations, including anti-money laundering and qualified investor frameworks
• Maintain the security and integrity of our communications
• Improve the quality and operation of our website

4. Legal Basis for Processing

We process personal data on the following legal bases, as applicable to your jurisdiction:

• Performance of a contract or engagement with the relevant counterparty
• Legitimate interests of the firm in operating our advisory platform, subject to your rights
• Legal obligations applicable to financial services and regulated activities
• Consent, where explicitly provided

5. Sharing of Information

We do not sell personal information. We may share information with:

• Qualified counsel, auditors, and tax advisors supporting transactions
• Banking, custody, and administration partners involved in execution
• Regulatory authorities, where required by law
• Technology service providers operating under appropriate confidentiality and data protection commitments

6. International Transfers

Lumen Capital operates across multiple jurisdictions. Personal data may be transferred to, stored in, or processed in countries other than your country of residence. Where such transfers occur, we apply safeguards consistent with applicable data protection frameworks, including the European Union General Data Protection Regulation (GDPR), the Brazilian Lei Geral de Proteção de Dados (LGPD), and equivalent regulations.

7. Data Retention

Personal data is retained only for as long as necessary to fulfill the purposes for which it was collected, including legal, regulatory, and contractual obligations. Onboarding records and transaction documentation are retained for the periods required by applicable financial services regulation.

8. Your Rights

Depending on your jurisdiction, you may have the following rights:

• Right of access to your personal information
• Right to correct inaccurate or incomplete data
• Right to erasure, subject to legal and regulatory retention requirements
• Right to restrict or object to certain processing
• Right to data portability
• Right to lodge a complaint with a supervisory authority

To exercise these rights, contact us at privacy@lumencapitaladvisory.com.

9. Cookies

Our website uses essential cookies for site functionality and may use limited analytics cookies, subject to your consent through the cookie banner. You can manage your preferences at any time by clearing your browser storage, which will trigger the consent prompt on your next visit.

10. Security

Lumen Capital applies organizational and technical measures designed to protect personal information against unauthorized access, alteration, disclosure, or destruction. No transmission over the internet can be guaranteed entirely secure, however.

11. Changes to This Notice

We may update this Privacy Notice from time to time. The "Last updated" date at the top of this page reflects the most recent revision. Material changes will be communicated through the website or directly to existing counterparties, as appropriate.

12. Contact

For privacy-related inquiries:

Lumen Capital
Privacy Office
privacy@lumencapitaladvisory.com